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• to each then current holder of an annual vendor permit. Each permit holder desiring renewal shall return the renewal application and the appropriate fee to the zoning administrator not later than the close of business on February 15. (b) Renewal permits shall then be issued to those holders of the seven special downtown mall vendor permits who: (1) Are in full compliance with the provisions of this article; (2) Have filed a timely application for such renewal; (3) Actually operated a vendor stand on the mall for at least fifteen days per month during the months of May through October of the preceding calendar year. Renewal permits shall be issued to all other renewal applicants for other categories of permits who have timely filed and paid • the appropriate fee, and are not otherwise in violation of this article. (c) No review by the board of architectural review or the downtown board of architectural review shall be required on a renewal application unless the applicant wishes to change the size, appearance or character of his or her vendor stand. (d) After renewal applications have been granted, if any permits for downtown mall vending locations remain, their availability shall be advertised by the zoning admin- istrator at least once in a newspaper of general circulation in the city. Proper applications received by the deadline specified in such notice shall be granted, by lottery if necessary. The fees of unsuccessful applicants shall be refunded. If mall vendor permits thereafter remain un- allocated they may be issued by the zoning administrator for the balance of the year on a first come, first served basis. Section 25-58. Denials of permits. Applications may be denied only on the basis of • nonconformity with any of the standards established directly or by reference in this article or noncompliance by the applicant with any other relevant law or regulation. Denials shall be in writing and state the reasons therefor. am